Lorry on one of the proposed routes to Roseacre Wood. Photo: DrillOrDrop

Updates from Day 6 of the reopened public inquiry on Cuadrilla’s plans to drill and frack at Roseacre Wood in Lancashire.

Today’s session, at Blackpool Football Club, will hear from Gerald Kells, the highways witness for Roseacre Awareness Group. The group opposes Cuadrilla’s  revised plans to manage lorry deliveries to the site. The plans include two additional lorry routes, 39 passing places and new traffic signals.

This afternoon the inquiry will hear the first public statements. We’ll report this testimony in a separate post here.

Key facts about the inquiry and links to all the DrillOrDrop reports from the inquiry here

Reporting at this event has been made possible by donations from individual DrillOrDrop readers.

Check here for key points from today’s hearing

• Evidence from Roseacre Awareness Group  highways expert
  • The absence of personal accidents does not mean a route is safe or suitable
  • Proposed traffic routes are ” inherently not safe and suitable”
  • Proposed passing places and traffic signals will make things worse for pedestrians and cyclists
  • No guarantee that Cuadrilla will use all three traffic routes
  • Good driver behaviour or education can’t be relied on
  • Cuadrilla is responsible for collecting traffic data – not RAG

Break

The inspector adjourns the inquiry until 3.30pm for the public statements. You can read updates from this session here

Cuadrilla questions Roseacre Awareness Group’s highway witness

Nathalie Lieven, for Cuadrilla (left), cross-examines Gerald Kells, the highways witness for Roseacre Awareness Group (RAG).

2.22pm Dagger Road traffic controls

Cuadrilla proposes to add traffic lights triggered by two heavy goods vehicles meeting. Mr Kells says the lights would work only for any other combination of vehicles or road users. There is no other mitigation, he says.

Ms Lieven says the previous passing places had been put in because of concerns that two Cuadrilla vehicles would meet. She says there are now two other routes and the traffic lights mean two HGVs cannot meet. The traffic management plan would also prevent two Cuadrilla HGVs meeting.

Mr Kells says it is not just a matter of two HGVs meeting. The road is too narrow for HGV or a car meeting. When the traffic lights are off, it does nothing for other road users. There is also the issue of confusion for these users.

Ms Lieven says there are already HGVs meeting other road users on Dagger Road. They are getting past each other, she says. There have been no recorded accidents on Dagger Road at all, she adds.

Mr Kells says there are two issues: Is the road suitable and what is the impact of the additional traffic? You have to consider both, he says. What will be the impact of adding 50 HGVs to a road that has few HGVs at present. The fact that there are no accidents now does not mean there will be no accidents if more HGVs are added. There is already an issue about whether that is a safe and suitable road now.

Ms Lieven says Dagger Road has good visibility because it is straight. Mr Kells says the narrow section of the road goes over a rise which affects visibility.

2.13pm Convoys

Mr Kells has said the issues of convoys would have to be considered for each route.

Ms Lieven says the choice of route for convoys will have to be assessed closer to the time and confidential. The very point of convoys is as a way of dealing with protests. Mr Kells says there is nothing to stop Cuadrilla using convoys outside of protest action.

Ms Lieven says it is too early to start planning for convoys. Mr Kells says this does not remove the issue of how convoys would negotiate the network. It is potentially important, he says.

Ms Lieven says there will be a choice to Cuadrilla of three routes for convoys. Mr Kells says the implications should be considered and there is nothing to suggest this has been done. Ms Lieven says it is in Cuadrilla’s interests to bring in convoys with the minimum amount of operational delay. Mr Kells says issues of parked cars in passing places needs to be considered in relation to convoys. He says:

“I am in ignorance about how convoys would be used in practice”.

Ms Lieven says a convoy on the Green Route could be escorted by a car. Mr Kells says this is RAG’s opportunity to raise this issue. If the Inskip defence site was unavailable, then only the Green Route would be available. Ms Lieven says Inskip would be closed only in emergencies. Mr Kells there could be a problem of the route through the Inskip site, including flooding. Ms Lieven says the council has not raised the issue of flooding in the Inskip site.

2.03pm Traffic increases

Ms Lieven puts it to Mr Kells that Cuadrilla’s assessment of highway safety has taken account of the existing profile of traffic on the routes and the maximum potential impact of traffic from the development. Mr Kells agrees.

Ms Lieven asks if there is a single highway safety issue where Cuadrilla has not used the right methodology. Mr Kells says he does not want to answer that question.

Ms Lieven says the Cuadrilla has the benefit of traffic data on construction and nine months of drilling at Preston New Road. Mr Kells says the Preston New Road figures could have been different if the weather or protest activity had been different. Ms Lieven says rainfall during construction was probably the worst case and the level of protest is difficult to predict. Mr Kells says 2015 would have been higher rainfall.

1.59pm Public rights of way network

Ms Lieven puts it to Mr Kells that there is no access to public footpaths after the first bend out of Roseacre towards Elswick. Mr Kells agrees but he says there is a circular walk along footpaths in combination with Roseacre Road. The use of the road may be various, he says.

1.50pm School buses

Ms Lieven says there is a pavement in Roseacre village where children wait for the school bus.

She puts it to Mr Kells that there would be about three heavy goods vehicles an hour. Mr Kells says we don’t know that.

Ms Lieven says children waiting for a bus would have to have a basic knowledge of highway safety. Mr Kells says the key issue is walking along the road and crossing it. Ms Lieven says parents have to confident at the moment that their child is up to the task of crossing the road.

Mr Kells rejects this approach. You can take out each of these elements individual but you are not answering the overall question. You have to look at the elements of the risk along all the routes. He says:

Discounting these problems one by one gives you a way round them for every location.

Ms Lieven asks “Are you saying that 25 lorries in and out is a severe residual impact on the safety of children?”. Mr Kells replies it is part of the overall impact.  It needs to be treated as material.

Ms Lieven asks how many extra HGVs would have an impact on the safety of children? Mr Kells says to come to a conclusion on safety you need to ask whether the road is suitable and what is the effect of extra HGVs on the route. This is not a suitable road for HGVs.

How many HGVs would have an impact, Ms Lieven asks. Is it zero, she says.

Mr Kells says it probably is zero but he says you do not need to come to a number to conclude that the road is not suitable.

1.41pm Impact on pedestrians

Ms Kells described the route from Roseacre to Elswick as a key pedestrian route. Ms Lieven says there was a pedestrian camera between Roseacre and Wharles. This counted a maximum of four people walking in a 12-hour day, she says. There were two leisure walkers, she says. Mr Kells says this was not the location he was raising.

Ms Lieven says it is 2.5km from Roseacre to Elswick. Mr Kells people may have been using the route to destinations on Roseacre Road. Ms Lieven says it would be a 5km round trip and not a particularly pleasant route. People in the audience object.

Ms Lieven produces a Google image of the road. There is a pavement out of the village and then extremely good visibility on the next section from the tea room onwards, she says. The impact on highway safety is material lower, she says.

Mr Kells says Cuadrilla needs to think about people from the caravan park, local residents, people going to the tea rooms. This would be somewhere I would not want to restrict pedestrians from being able to walk safely.

Ms Lieven says the issue for the inspector is highway safety. There is good visibility on the second part of the route, she says. Mr Kells questions this.

1.37pm Survey of vulnerable users

Cuadrilla did not survey pedestrians walking along Roseacre Road between Roseacre village and Elswick.

Mr Kells says his biggest concern on data collection is about surveying of pedestrians in villages. This is not the only place where pedestrians were not surveyed, he says.

Ms Lieven says RAG and Lancashire County Council were sent the methodology before the surveys were carried out. This included the locations where pedestrians would be surveyed, she says. The county council did not raise concerns, she adds. This had been raised by the council at the 2016 inquiry, Ms Lieven says. Ms Lieven says RAG did not respond to the letter about the methodology.

Mr Kells says he has not been shown a response. He says responsibility for choice of the camera locations rests with Cuadrilla. He adds that places were missing in the survey to do an assessment on pedestrian impacts.

Ms Lieven says RAG did not raise the issue in its response to the county council consultation.

Ms Lieven suggests there has been five or six months for RAG to carry out a traffic survey. Mr Kells replies this is a matter for RAG.

1.15pm Accident data

Ms Lieven puts it to Mr Kells that the accident record it is a material consideration. He agrees. Ms Lieven says the accident record for vulnerable road users and involving HGVs is particularly relevant. Mr Kells agrees.

Ms Lieven puts it to Mr Kells that transport policy requires the inquiry to look at the personal injury accident record over the past three years. Mr Kells says it is not as prescriptive as this suggests. Ms Lieven says a transport assessment should include “not more than three years’ data”.

Mr Kells it can be instructive to look back further to identify accident clusters. He looked back over 18 years. The clustering of accidents at junctions become clearer over time, he says. But he agrees the data shows it is not a poor accident area. He confirms there are no accidents relating to heavy goods vehicles (HGVs) and only two serious accidents.

One of the serious accidents is not relevant to the Cuadrilla proposals, Ms Lieven says, because it happened in the dark. The other serious accident was a junction between White House Lane and the A586, not on Cuadrilla’s highways route. Cuadrilla had assessed this junction as unsuitable for HGVs.

Ms Lieven puts it to Mr Kells if there was an accident record at a junction on the proposed route he would rely on it. Mr Kells says the first issue is to look at the safety of the junction and then look at the accident data.

1.04pm  Planning policy and highway safety

Ms Lieven, for Cuadrilla, says under the National Planning Policy Framework  a development should be only refused on transport grounds if the residual cumulative impact is severe.

This would take into account any mitigation, Ms Lieven says. Mr Kells disagrees. He says residual means the impact of Cuadrilla’s traffic on the network.  But he accepts that the mitigation should be taken into account.

Ms Lieven says the inquiry is to report only on highway safety issues. Mr Kells says he cannot give an answer on safety without assessing the suitability of the route. He assumes this will apply for the inspector and the Secretary of State, particularly for the red and green routes where there has been no assessment of  suitability of the routes. Mr Kells says:

“My opinion is that you cannot assess safety without assessing suitability.”

Ms Lieven says it is a non-sequitur that something is unsuitable it is also unsafe. Mr Kells the two are not the same but they are intimately linked and should be looked at together.

1.03pm Inquiry resumes

12.29pm Break

The inquiry breaks until 1pm

Roseacre Awareness Group highways witness

Ben Du Feu, for Roseacre Awareness Group (RAG), introduces Gerald Kells, the RAG highways witness.

Gerald Kells. Photo: Cuadrilla webcast

12.25pm Conclusions

Mr Kells says:

“My view is that these routes are not safe and suitable. They are inherently not safe and suitable and the mitigation proposed, particularly for vulnerable road users will, if anything make matters worse in many cases.”

He says he bases this conclusion on:

• Physical deficiencies of the route
• Assessment of risk along the routes
• Proposed mitigation and the impact on all road users

“My conclusion is that these are not safe and suitable routes”.

12.22pm Convoys

Cuadrilla proposes to bring some vehicles in by convoy, including out of hours.

Mr Kells says we don’t know much about convoys. This is important in the context of passing places and visibility, he says. If a convoy meets vehicles coming in the opposite direction this is much more complex than one heavy goods vehicle meets a car, he says.

There are additional issues for convoys on Roseacre Road, Mr Kells adds.

12.15pm Junctions

Mr Kells is asked about data on the use junctions. He says this came up at the previous inquiry, particularly on the Dagger Road/Station Road/Treales Road junction.

He says Cuadrilla told the current inquiry that 10,000 vehicles navigated this junction from Station Road over an eight-year period. But he says we don’t know what they did at the junction and whether they continued to Dagger Road..

Nathalie Lieven says the key issue is the movement out of Station Road into Treales Road.

Mr Kells it is important to know how many did the proposed manoeuvre from Station Road, via Treales Road into Dagger Road.

12.11pm Three lorry routes

Cuadrilla now proposes three routes: Red, Green and Blue.

Mr Kells says there is no guarantee that Cuadrilla will spread the heavy goods vehicles across all three routes.

“I am not convinced why they should not use one route all the time and still fulfill the conditions. We don’t know which route it will use or which route it will use for particular HGVs.”

Mr Kells says if the Inskip defence site were not available, the only available route would be the Green Route. There was a suggestion that deliveries may be delayed but the would not have to.

12.02pm Heavy goods vehicles

Mr Kells says the previous inspector had been aware of the existing use of the original traffic route by heavy goods vehicles (HGVs). She had concluded that the route was little used by the largest HGVs.

Mr Kells says the number of HGVs generated by the site, forecast by Cuadrilla, has increased.

The programme proposed for the site could be faster or slower,he says. The lesson of Preston New Road is that there could be more HGVs. The only guarantee we have is that there is a condition that there will be no more than 50 HGVs a day, he adds. Some of the tables of proposed lorry movements could change, he says.

A longer time with slightly fewer HGVs does not necessarily answering the problem of the HGVs being unsuitable for those roads, Mr Kells says.

11.50am Guidelines on impact assessments

Gerald Kells, the RAG highways expert, questions what he calls Cuadrilla’s “mechanistic” approach to the impact assessment.

He says the guidelines screen out small increases in traffic. But at Roseacre Wood there would be a change in the volume and character of the traffic at a number of sensitive locations. I would treat with caution that you can take the guidance from which you can create tables and conclude that there is no conflict with national planning policy.

11.44am Other proposed mitigation

Cuadrilla proposes to train drivers delivering to its site.

Gerald Kells, for RAG, says:

“You cannot rely on the behaviour of drivers. You cannot rely on the education of drivers.”

On Cuadrilla’s plan to limit deliveries to weekdays, Mr Kells says people should be able to use the roads when they want to. The decision to prevent deliveries on weekends suggest there is a need to mitigate the impact.

Limits on deliveries on the Red Route during school drop-off and pick-up times does not help travel to schools on other routes.

“The mitigation does not answer the impact of vulnerable users”

He says the result is likely to be that people will no longer use the three routes for walking, cycling and horse riding.

On the proposed three routes, Mr Kells says:

“We have no guarantee how the routes will be used, we have to assume the worst case for each route.”

Mr Kells questions whether Cuadrilla has actively planned for the impact of its vehicles on vulnerable road users.

11.41am RAG survey

Mr Kells is asked about whether RAG should have done a traffic survey at the previous inquiry. He says a survey would have been treated with scepticism if it had been carried out.

The previous inspector, at the 2016 inquiry, said RAG should not be criticised for not carrying out a survey, Mr Kells says.

11.36am Location of pedestrian cameras.

Mr Du Feu, for RAG, asks Mr Kells about the letter from Cuadrilla to the group about the proposed location of cameras to count pedestrians.  Mr Kells says RAG did not have an adviser this time.

The letter says it “encloses a note for your information”. This suggests to me that Cuadrilla did not expect RAG to respond to the letter, Mr Kells says. The letter says the survey would be done to “industry standards” and that Cuadrilla had met with Lancashire County Council.

Those points would have the effect of discouraging a response from RAG, Mr Kells says. This is not a letter I would have responded, he adds.

My immediate reaction to Roseacre Road is that this a key pedestrian route”, Mr Kells says.

“I do not understand why RAG is being criticised for not responding. But the primary responsibility lies with the appellant [Cuadrilla]”

Mr Kells says the methodology does not capture the key pedestrian movements.

11.28am Walking to bus stops

Mr Kells says it is important to take account of people walking through villages.

there is no mitigation for children crossing a road on the proposed Blue Route at Clifton to reach a bus stop.

From evidence to the 2016 inquiry, Cuadrilla should be aware of the desire lines of people travelling to bus stops, he says.

Professional guidance recommends counts of people walking through villages to get reliable evidence, Mr Kells says. There have been no specific checks on pedestrian use in the villages, he adds.

Mr Kells says Cuadrilla has produced a “fairly robust” idea of cyclists and they can be compared with the movements of cars. He says he is unsure about the quality of the data on horse riders.

He questions Cuadrilla’s methodology on counting pedestrians. The location of cameras is unhelpful, he says.

11.24pm Dagger Road traffic signals

Mr Kells says Dagger Road, on the proposed Blue Route,  is particularly narrow road. Cuadrilla proposes to install traffic signals that will prevent the meeting of two HGVs travelling in opposite directions. There is no benefit if a car or HGVs meet, he says.

Previous proposals had included two passing places on Dagger Road but these have now gone, Mr Kells says. At best the traffic signals have no benefit for a car and an HGV and at worst they will confuse people.

11.06am Passing places

Gerald Kells, RAG’s highways expert, says “the route is clearly unsuitable because Cuadrilla needed to put in this level of mitigation”. The assumption is that the road is unsuitable for your purpose if this is needed.

He picks an example a proposed passing place on Roseacre Road on a bend. He says at this point there are very few of the largest heavy goods vehicles. The chance of two of these vehicles meeting is not highly likely, he says. But if it does happen there is nowhere for pedestrians to go because the passing place has taken away the verge.

What is more likely is that a Cuadrilla HGV will meet another vehicle, Mr Kells says. The pedestrian will still have nowhere to go. A van or smaller lorry will be going at a faster speed than the Cuadrilla HGV. They may not see the pedestrian.

The mitigation has also changed the safety and suitability of this section of road for cyclists and pedestrians, Mr Kells says. The scheme proposes to widen the road and allow cars to drive faster. Vulnerable road users will be less able to see a car and the vulnerable user will be less able to see traffic because they are forced into the verge.

If a pedestrian was walking from Roseacre to Elswick they would have negotiate 10 or 11 passing places, Mr Kells says. The chance of pedestrians meeting vehicles increases at every passing place. The safety problems is not solved by engineering visibility solutions, he says.

Mr Kells says there is a good knowledge of cyclists but there is no information from Cuadrilla of how many pedestrians use this section of Roseacre Road. There are attractions that will draw people in, he says. But there is no Cuadrilla data for people walking on this section of the road.

Mr Kells asks: “Should we be making this road unsafe for pedestrians and cyclists?”

The large number of passing places is not resulting in something that is not safe or suitable, Mr Kells says.

He adds: The newly-proposed Green Route is likely to have more pedestrians than the original route, now called the Blue Route.

The previous inspector had said the evidence given by RAG about the use of the road network by pedestrians and cyclists was significant.

Mr Kells says his observations on the Roseacre Road passing place apply to other proposed passing places on bends and visibility over third party land. The proposals go beyond those that had been rejected at the previous inquiry, Mr Kells adds.

10.56am Accident data

Gerald Kells, RAG’s highways expert, introduces accident data from 2012-present, from a junction between White House Lane and the A586.

The junction is not on a proposed traffic route. But Mr Kells says this was discounted by Cuadrilla as a possible route. David Bird, for Cuadrilla, had said two heavy goods vehicles (HGVs) could not navigate the junction safely even with mitigation.

There were no personal injury accidents on this junction, Mr Kells says. But this junction was rejected for a route by Cuadrilla.

RAG does not rely on historic accident data, Mr Kells says. If people do not feel they cannot do what they ought to be able do because they perceive it to be unsafe it is not a suitable route, Mr Kells says. That is a demonstration that the requirement of the National Planning Policy Framework has not been met, he adds.

Mr Kells says the current inspector should follow the approach of the 2016 inspector – supported by the Secretary of State – and treat historic accident data with caution.

10.47am Safe and suitable route

Mr Kells (pictured left), the RAG transport witness, tells the inquiry it is possible to make a route safe if it is unsuitable. He says:

“An absence of personal injury accidents does not demonstrate that a route is both safe and suitable.”

He says the route should allow everyone to go about their usual travel plans. He stresses the importance of giving priority to pedestrians and cyclists.

A transport assessment is intended to show whether the impact of a development on the highway is severe, as required under national planning policy.

10.46am Gerald Kells background

The inquiry hears that Mr Kells is an adviser on sustainable transport. He gave evidence on behalf of RAG to the 2016 inquiry.

10.39am Roseacre Awareness Group statement

Ben Du Feu (pictured above) hands in a revised statement of common ground on the inquiry.

He says Cuadrilla had control of the process of producing the statement, he says. Roseacre Awareness Group (RAG) had agreed to part of the statements in the document but not all. The group felt the inspector would not have the full picture.

The inspector, Melvyn Middleton, says he needs to know where the group agrees and disagrees on the proposed mitigation measures, such as passing places, and why.

Mr Du Feu says the group is reviewing these issues.

10.31am Cuadrilla on passing places

Nathalie Lieven, for Cuadrilla, raises an issue from Lancashire County Council’s evidence on visibility. Neil Stevens, for the council, had said there was a need for drivers to be able to see beyond the passing place to which it was approaching.

Ms Lieven says she needs to see “precisely” what Mr Stevens is saying in writing. The point had come in without it being put down properly., she says. “I am not sure what Mr Stevens is requiring”, she says.

Alan Evans, for the council, says Mr Stevens will produce a note on the issue with a plan.

Ms Lieven says Cuadrilla’s highways expert needs to be able to see the note.

10.30am Hearing begins

The inquiry inspector, Melvyn Middleton (above), opens the formal part of the inquiry.

9.30am Discussion on conditions

The inquiry inspector, Melvyn Middleton, meets barristers from Cuadrilla, Lancashire County Council and Roseacre Awareness Group  for initial discussions on any conditions should the appeal be allowed.

Roseacre Wood Fracking Inquiry Day 1
Roseacre Wood Fracking Inquiry Day 2
Roseacre Wood Fracking Inquiry Day 3
Roseacre Wood Fracking Inquiry Day 4
Roseacre Wood Fracking Inquiry Day 5

Reporting from this inquiry has been made possible by individual donations to DrillOrDrop